Agroterrorism and Ecoterrorism: A Survey of Indo-American ...

From the SelectedWorks of Kevin H. Govern

January 2009

Agroterrorism and Ecoterrorism: A Survey of Indo-American Approaches Under Law and Policy toPrevent and Defend Against the Potential ThreatsAhead

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AGROTERRORISM AND ECOTERRORISM:A SURVEY OF INDO-AMERICAN APPROACHES UNDER LAW

AND POLICY TO PREVENT AND DEFEND AGAINST

THESE POTENTIAL THREATS AHEAD

Kevin H. Govern*

Terrorism exploits the freedom our open societies provide, act-ing to destroy our freedoms. The United States and India must worktogether in all possible forums to counter all forms of terrorism. Wecannot be selective in this area. We must fight terrorism wherever itexists, because terrorism anywhere threatens democracy everywhere.1

In the war on terrorism, the fields and pastures of America’sfarmland might seem at first to have nothing in common with the towersof the World Trade Center or busy seaports. In fact, however, they aremerely different manifestations of the same high-priority target, theAmerican economy.2

* The author is an Assistant Professor of Law at Ave Maria School of Law, anInstructor of Legal Studies at the California University of Pennsylvania, and was aformer Assistant Professor of Law at the United States Military Academy. This articleis based upon a conference paper presented at the Indian Society of InternationalLaw’s Fifth Annual International Conference on International Environmental Law onDecember 9, 2007, in New Delhi, India. The author gratefully acknowledges thetremendous assistance of Ms. Laura Burns, Class of 2011, Ave Maria School of Lawand Ms. Sue Berendt, Ave Maria School of Law, in the preparation of this article.Any errors or omissions are solely the responsibility of the author.1 U.S. Department of State, Text of Dr. Manmohan Singh’s Address to the JointSession of the U.S. Congress, http://www.america.gov/st/washfile-english/2005/July/200507261027051CJsamohT0.3803217.html [hereinafter Singh] (last visited Mar. 1,2009); see also N. Ravi, India, U.S. Must Make Common Cause Against Terrorism:Manmohan Singh, HINDU (India), July 20, 2005, at Front Page, available at 2005WLNR 11391762.2 Stan Cox, “Agroterrorists” Needn’t Bother, COMMONDREAMS.ORG, Dec. 13, 2005,http://www.commondreams.org/views05/1213-26.htm (quoting U.S. Senator SusanCollins).

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224 Florida Coastal Law Review [Vol. X:223

I. INTRODUCTION

“Agroterrorism is a subset of bioterrorism, and is defined as thedeliberate introduction of an animal or plant disease with the goal ofgenerating fear, causing economic losses, and/or undermining socialstability.”3 Its partner in crime is ecoterrorism, “the use or threateneduse of violence of a criminal nature against innocent victims or propertyby an environmentally-oriented, subnational group for environmental-political reasons, or aimed at an audience beyond the target, often of asymbolic nature.”4 Furthermore, “[a]s recently as June 2004, the FBIdesignated ‘eco-terrorism’ . . . as the [U.S.’] number one militant chal-lenge emanating from inside its own borders.”5

India is the world’s fourth largest agricultural power, with agri-culture representing about twenty percent of India’s Gross DomesticProduct (GDP)6 and employing almost two-thirds of the active popula-tion. With the largest number of livestock in the world, India is one ofthe world leaders in production of milk, fruits, vegetables, wheat, rice,tea, cotton, and sugar.7 By comparison, agricultural production com-prises only about one percent of the U.S. GDP, however that productionaccounts for sixty percent of the world’s total agricultural production,

3 JIM MONKE, CONG. RESEARCH SERV., AGROTERRORISM: THREATS AND

PREPAREDNESS 1 (2007), available at http://www.fas.org/sgp/crs/terror/RL32521.pdf.4 Federal Bureau of Investigation, James F. Jarboe, “The Threat of Eco-Terrorism,”Testimony of James F. Jarboe, Domestic Terrorism Section Chief, CounterterrorismDivision, FBI Before the U.S. House Resources Committee, Subcommittee on Forestsand Forest Health February 12, 2002, http://www.fbi.gov/congress/congress02/jarboe021202.htm [hereinafter Jarboe] (last visited Mar. 1, 2009).5 PETER CHALK ET AL., RAND CTR. FOR TERRORISM RISK MGMT. POLICY, TRENDS IN

TERRORISM: THREATS TO THE UNITED STATES AND THE FUTURE OF THE TERRORISM

RISK INSURANCE ACT 47 (2005), available at http://www.rand.org/pubs/monographs/2005/RAND_MG393.pdf. Author’s note: The many definitions and interpretations ofterrorism point out obvious challenges to interagency action.6 The Federation of International Trade Associations, India, http://www.fita.org/countries/india.html (last visited Mar. 1, 2009); see also Macro-economic Overview ofIndia: Agriculture, http://indiaonestop.com/economy-macro-agro.htm (last visitedMar. 1, 2009) (“Agriculture’s share in India’s GDP has declined in recent years, thusmarking a structural shift in the composition of the GDP. Traditionally, agricultureaccounted for two-fifths of the GDP, but in recent times it has witnessed a decliningtrend.”).7 Id.



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2009] Govern 225

including the largest production of cheese, corn, soybeans, and tobaccoin the world, more wheat and corn exported than any other nation, andthe third leading exporter of rice.8

Agroterrorism’s first order effect would be the disruption of In-dian or U.S. agricultural sectors. Killing farm animals, contaminatingvegetation, and disrupting supplies of unadulterated natural resourcesmay become the means to the diabolical ends of causing economic dam-age, social unrest, and loss of confidence in government.9

While India and the U.S. have not yet been directly assailed bylarge-scale agroterrorist and ecoterrorist threats, both the events of Sep-tember 11, 2001 and November 26-29, 2008, in the United States andIndia respectively, were unforgettable terrorist acts that took lives anddestroyed property on a heretofore unthinkable scale. Both the U.S. andIndia face the very real potential that international terrorists, militaryopponents, economic opportunists, domestic terrorists or criminals, andmilitant animal rights activists will at some point in the future bringtheir tentative plans to fruition as positive events furthering their agen-das.10 As both nations combat crime and terrorism domestically andabroad, laws and policies at the state and federal levels have beenpassed and international cooperation undertaken to prevent, defendagainst, and prosecute such actions.11

8 The Federation of International Trade Associations, United States, http://fita.org/countries/us.html (last visited Mar. 1, 2009) (“Though agriculture contributes only[one percent] the GDP but produces [sixty percent] of the world’s agriculturalproduction but benefits from huge subsidies. It is the largest producer of cheese, corn,soybeans, and tobacco in the world. It is also the world’s leading exporter of wheatand corn, and ranks third in rice exports.”); see Appendix 1 for “Continental U.S.Agriculture, by Location.”9 See MONKE, supra note 3, at 1 (“The goal of agroterrorism is not killing cows orplants. These are the means to the end of causing economic crises in the agriculturaland food industries, social unrest, and loss of confidence in government.”).10 See generally Ravi, supra note 1 (“Prime Minister Manmohan Singh . . . said thatIndia and the U.S. must make common cause against terrorism whose rise wasthreatening open societies more than ever before.”).11 See, e.g., id. (mentioning the U.S.-India Global Democracy Initiative was created to“help build democratic capacities in all societies” and “[n]oting that democraticsocieties with established institutions must help other nations strengthen theirdemocratic values and institutions”).



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This article will survey such efforts in India and the U.S., withthe suggestion of a three-pronged, combined, interagency approach topreventing agroterrorist and ecoterrorist attacks, enabling both nationsto forge ahead in this critical effort.

II. THE CHALLENGE: TO DEFINE TERRORISM, LET ALONE

AGROTERRORISM OR ECOTERRORISM

The history of mankind has been replete with acts by individu-als, groups, and states whereby the end result was to create fear, eco-nomic losses, and/or an undermining of social and political stability.12

These acts have come about despite cultural and religious exhortationsand legal prohibitions against violence to man and beast alike, contami-nating the environment, or adulterating resources used for man’sbenefit.13

Without delving into ancient history and terroristic acts, not thencalled terrorism, we find the birth of the term terrorism during the post-French Revolution Jacobins Reign of Terror 1793-1794—the Frenchword terrorisme found root in the Latin verb terrere (causing to trem-ble).14 Stanford University’s Encyclopedia of Philosophy notes that by“the second half of the [nineteenth] century, there was a shift in both

12 See e.g., MONKE, supra note 3, at 1 (citing the terrorist attack in the United Stateson September 11, 2001).13 See e.g., MARTIN PALMER WITH VICTORIA FINLAY, WORLD BANK, FAITH IN

CONSERVATION: NEW APPROACHES TO RELIGIONS AND THE ENVIRONMENT, at xiii,available at http://siteresources.worldbank.org/INTBIODIVERSITY/214584-1112712965549/20480342/FaithInConservationNewApproachesPreface2003.pdf(“Imagine you are busy planting a tree, and someone rushes up to say that the Messiahhas come and the end of the world is nigh. What do you do? The advice given by therabbis in a traditional Jewish story is that you first finish planting the tree, and onlythen do you go and see whether the news is true. The Islamic tradition has a similarstory . . . .”). Palmer and Finlay have been cited with authority for scholarship intowell-known, popular religious texts, as determining elements for helping turn failingenvironmental management policies into success. See F. Dahdouh-Guebas et. al.,Analysing Ethnobotanical and Fishery-Related Importance of Mangroves of the East-Godavari Delta (Andhra Pradesh, India) for Conservation and ManagementPurposes, 2 J. ETHNOBIOLOGY & ETHNOMEDICINE 24 (2006), available at http://www.pubmedcentral.nih.gov/picrender.fcgi?artid=1475843&blobtype=pdf.14 Stanford Encyclopedia of Philosophy, Terrorism, § 1.1.1, http://plato.stanford.edu/entries/terrorism/ (last visited Mar. 1, 2009).



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descriptive and evaluative meaning of the term” to include anarchy andother revolutionary activities, as well as nationalist group violence, in-cluding: “extreme, dramatic deeds that would strike at the heart of theunjust, oppressive social and political order, generate fear and despairamong its supporters, demonstrate its vulnerability to the oppressed, andultimately force political and social change.”15

Among many of the world’s representative religious faiths, ter-rorism targeting agriculture and ecological resources would be anath-ema.16 Vegetarians, vegans, and animal rights activists, too, will citewith authority religious tracts and tenets as authoritative sources in op-position to violence against nature and agricultural resources.17 For in-stance, in Hinduism, from the epic Bhagavad Gita (The Lord’s Song),comes the admonition that “One is dearest to God who has no enemiesamong the living beings, who is nonviolent to all creatures.”18 From theRig-Veda 6:48:17 comes: “[d]o not cut trees, because they remove pol-lution.”19 From the Yajur-Veda 5:43 comes: “[d]o not disturb the skyand do not pollute the atmosphere[,]” and from Charak Sanhita that:“[d]estruction of forests is taken as destruction of the state, and refores-tation an act of rebuilding the state and advancing its welfare. Protec-tion of animals is considered a sacred duty.”20 Mahavira, founder of theJain religion said “[m]ay all that have life be delivered from suffer-ing.”21 The Jain scripture, called the Yogashastra, offers the first truthof Jainism that “[n]on-injury to all living beings is the only religion[,]”from the Sila-Prabhrita comes: “[m]ercy to living beings, self restraint,

15 Id.16 See Dahdouh-Guebas et al., supra note 14, at 36 (noting that “the message of theBhagavad Gita” which is “the dialogue between the Hindu Lord Sri Krishna . . . andhis intimate disciple” is to “‘conserve ecology or perish’”).17 See, e.g., American Vegetarian, Quotable Quotes, http://spot.acorn.net/av/avquotes.html (last visited Mar. 1, 2009) (listing religious quotes that vegetarians use asarguments in support of vegetarianism); see also Animal Rights Quotes, http://www.animalliberationfront.com/Saints/Authors/Quotes/SortQuotesRelig.htm (last visitedMar. 1, 2009) (listing religious quotes that animal rights activists use as argumentsagainst killing animals).18 Id. (“Sanskrit word ahimsa means nonharm to all life.”).19 C.G. Weeramantry, Islam, Buddhism, Hinduism and the Environment, ENERGY

BULL., July 7, 2007, http://www.energybulletin.net/node/32153.20 Id.21 Animal Rights Quotes, supra note 18.



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truth, honesty, chastity and contentment, right faith and knowledge, andausterity are but the entourage of morality.”22 Jews and Christians findin Genesis (Bereshit in Hebrew) 1:29 God’s command that “[b]ehold Ihave given you herbyielding seed. To you it shall be for meat.”23 An-other version of that same verse says “[a]nd God said, [b]ehold, I havegiven you every herb-bearing seed which is upon the face of the earth,and every tree in which is the fruit of a tree yielding seed: to you itshall be as meat . . . .”24 Also from Isaiah 66:3, “[h]e that slayeth an oxis as if he slew a human.”25 For Muslims, the Qur’an’s Surah 6:38 setsforth that “[t]here is not an animal on the earth, nor a flying creature ontwo wings, but they are people like unto you.”26

In modern times, agroterrorism expert Steve Cain notes that dur-ing armed conflict, cultural and religious impediments to agroterrorismand ecoterrorism, let alone legal restraints, have been overcome in war-fare between and among various states.27 Specifically, during WorldWar I, German forces “clandestinely inoculated horses and mules beingshipped from U.S. ports to the Allies with anthrax and glanders . . . .”28

(albeit causing no instances of human illness) and attempted to “[i]nfectdraft, cavalry, and military livestock between 1915 and 1918 inRomania, Spain, Norway, Argentina, and the U.S.”29 “This was part ofGermany’s larger biological sabotage program,” and “Japan is allegedto have used animal and plant pathogens, including rinderpest and an-thrax, against Russia and Mongolia in 1940.”30

22 Id.23 American Vegetarian, supra note 18, at 1.24 Animal Rights Quotes, supra note 18, at 4.25 Id. at 5.26 Id. at 9.27 See generally STEVE CAIN, PURDUE U., AGROTERRORISM: A PURDUE EXTENSION

BACKGROUNDER, Sept. 24, 2001, http://www.ces.purdue.edu/eden/disasters/agro/Agroterrorism.doc (citing 1 JULIAN PERRY ROBINSON & MILTON LEITENBERG,STOCKHOLM INT’L PEACE RESEARCH INST., THE PROBLEM OF CHEMICAL AND

BIOLOGICAL WARFARE: THE RISE OF CB WEAPONS, 216-17 (1971)) (discussingseveral instances of agroterrorism and ecoterrorism during World War II).28 Id. at 3.29 Id.30 Id.



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Russia’s Bolsheviks and Germany’s Nazi Party exercised stateacts to evoke terror, and by the “1930s and 1940s [and beyond], internalstate terrorism continued to be practiced by military dictatorships inmany parts of the world,” while insurgents and so-called freedom fight-ers sometimes came to portray their acts of violence as “struggle forliberation and [sought] to be considered and treated as soldiers ratherthan terrorists or criminals.”31

Cain noted how the instrumentalities for agroterrorism andecoterrorism came into the fore “during World War II, [as] Canada,Great Britain, Japan, the United States, and the USSR studied manyanimal and plant diseases for offensive and defensive programs.”32

Biological research persisted beyond the 1972 Biological Weap-ons Convention (BWC); the U.S. continued defensive research, the So-viet biological weapon (BW) program “grew during the 1970’s and1980’s,” and Iraq was “known to have developed a BW potential. . . .”33

The world’s legal landscape is replete not only with those inter-national laws and conventions addressing biological and toxic weaponsthreats, but also with laws and policies regarding terrorism. Over adozen United Nations (UN) conventions and protocols relate to and de-fine terrorism,34 not counting national laws or other regional treaties and

31 Stanford Encyclopedia of Philosophy, supra note 15, § 1.1.4.32 CAIN, supra note 28, at 2. “Anthrax, brucellosis, and glanders, which are bothantipersonnel and antianimal agents, were all evaluated for mass production.Defensive work was [also] done on rinderpest, Newcastle disease, and fowl plague.”

“Crop diseases evaluated and/or produced for potential agroterrorism included:late blight of potato, rice blast, brown spot of rice, rubber leaf blight, Southern blight,and wheat rusts.” Id.33 Id. at 2-3 (citing TOM MANGOLD & JEFF GOLDBERG, PLAGUE WARS: A TRUE

STORY OF BIOLOGICAL WARFARE 65 (1999) and KEN ALIBEK & STEPHEN

HANDELMAN, BIOHAZARD 273 (1999)).34 See, e.g., International Convention for the Suppression of Acts of NuclearTerrorism, G.A. Res. 59/290, U.N. Doc. A/RES/59/290 (April 13, 2005), available athttp://untreaty.un.org/English/Terrorism/English_18_15.pdf; International Conventionfor the Suppression of the Financing of Terrorism, G.A. Res. 54/109, U.N. Doc. A/RES/54/109 (Dec. 9, 1999), available at http://www.un.org/law/cod/finterr.htm;International Convention for the Suppression of Terrorist Bombings, Dec. 15, 1997,2149 U.N.T.S. 256, available at http://untreaty.un.org/English/Terrorism/Conv11.pdf;



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agreements!35 Just selecting one such regional agreement, article 1 ofthe European Union’s Council Framework Decision on Combating Ter-rorism includes in its definition of terrorism the aim of “destabilising ordestroying the fundamental political, constitutional, economic or social

Convention on the Marking of Plastic Explosives for the Purpose of Detection, Mar. 1,1991, 2122 U.N.T.S. 359, available at http://treaties.un.org/doc/db/Terrorism/Conv10-english.pdf; Convention for the Suppression of Unlawful Acts against theSafety of Maritime Navigation, Mar. 10, 1988, 1678 U.N.T.S. 221, available at http://untreaty.un.org/English/Terrorism/Conv8.pdf; Protocol for the Suppression ofUnlawful Acts against the Safety of Fixed Platforms Located on the Continental Shelf,Mar. 10, 1988, 1678 U.N.T.S. 303, available at http://untreaty.un.org/English/Terrorism/Conv9.pdf; Convention for the Suppression of Unlawful Acts against theSafety of Civil Aviation, Sept. 23, 1971, 974 U.N.T.S. 177, available at http://untreaty.un.org/English/Terrorism/Conv3.pdf; Convention on the Physical Protectionof Nuclear Material, Mar. 3, 1980, 1456 U.N.T.S. 125, available at http://untreaty.un.org/English/Terrorism/Conv6.pdf; International Convention against the Taking ofHostages, Dec. 17, 1979, 1316 U.N.T.S. 205, available at http://untreaty.un.org/English/Terrorism/Conv5.pdf; Convention on the Prevention and Punishment ofCrimes against Internationally Protected Persons, including Diplomatic Agents, Dec.14, 1973, 1035 U.N.T.S. 167, available at http://untreaty.un.org/English/Terrorism/Conv4.pdf; Convention for the Suppression of Unlawful Seizure of Aircraft, Dec. 16,1970, 1973 U.N.T.S. 106, available at http://untreaty.un.org/English/Terrorism/Conv2.pdf; Convention on Offences and Certain Other Acts Committed on BoardAircraft, Sept. 14, 1963, 704 U.N.T.S. 219, available at http://untreaty.un.org/English/Terrorism/Conv1.pdf).35 See, e.g., Convention of the Organization of the Islamic Conference on CombatingInternational Terrorism, Res. No. 59/26-P, Annex (July 1, 1999), available at http://www.arabhumanrights.org/publications/regional/islamic/iconf-combating-terrorism99e.pdf; OAU Convention on the Prevention and Combating of Terrorism,July 14, 1999, 2219 U.N.T.S. 179, available at http://untreaty.un.org/English/Terrorism/oau_e.pdf; Treaty on Cooperation among the States Members of theCommonwealth of Independent States in Combating Terrorism, June 4, 1999,available at http://treaties.un.org/doc/db/Terrorism/csi-english.pdf; Arab Conventionon the Suppression of Terrorism, April 22, 1998, available at Columbia UniversityPress, Columbia International Affairs Online, http://www.ciaonet.org/cbr/cbr00/video/cbr_ctd/cbr_ctd_27.html (last visited Mar. 1, 2009); SAARC Regional Convention onSuppression of Terrorism, Nov. 4, 1987, available at http://treaties.un.org/doc/db/Terrorism/Conv18-english.pdf; European Convention on the Suppression ofTerrorism, January 27, 1977, 1137 U.N.T.S. 93, available at http://treaties.un.org/doc/db/Terrorism/Conv15-english.pdf; OAS Convention to Prevent and Punish the Acts ofTerrorism Taking the Form of Crimes against Persons and Related Extortion that areof International Significance, Feb. 2, 1971, 1438 U.N.T.S. 93, available at http://treaties.un.org/doc/db/Terrorism/Conv16-english.pdf.



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structures of a country . . . .”36 Focusing on Indo-American approaches,international and domestic political considerations shaped the debates inIndia and in the U.S. over respective antiterrorism laws.37 Notably,those political considerations include the “UN Security Council’s ef-forts to implement and enforce Resolution 1373, the mandatory resolu-tion adopted after the September 11, 2001 terrorist attacks underChapter VII of the UN Charter.”38 Fordham Law School Professor AnilKalhan makes the distinction that, “[t]he Resolution does not define‘terrorism’ or ‘terrorist acts,’ leaving each state to define those terms foritself.”39 Kalhan aptly notes that “Resolution 1373 also ‘calls upon’states to become parties to the [then] twelve existing international con-ventions and protocols concerning terrorism . . . .”40

Even though national and international lawmakers have “exten-sively legislated against ‘terrorism’ and ‘terrorist acts,’” Kalhan notesthat the precise definition of those terms “has been a major challenge.”41

Professor Kalhan categorizes India’s laws combating terrorisminto three groupings:

(1) constitutional provisions and statutes authorizing thedeclaration of formal states of emergency and the use ofspecial powers during those declared periods, (2) consti-tutional provisions and statutes authorizing preventivedetention during non-emergency periods, and (3) sub-

36 Council of the European Union, Council Framework Decision of 13 June 2002 onCombating Terrorism, OFFICIAL J. EUR. COMMUNITIES, at 4, available at http://www.statewatch.org/news/2002/jul/frameterr622en00030007.pdf.37 See Anil Kalhan et al., Colonial Continuities: Human Rights, Terrorism, andSecurity Laws in India, 20 COLUM. J. ASIAN L. 93, 98 (2006).38 Id.39 Id. at 214.40 Id. at 214 n.486. Additional actions called for included full implementation of“those agreements and previous Security Council resolutions addressing terrorism, toimprove border security, and to exchange information with and provide judicialassistance to other member states in terrorism-related criminal proceedings.”41 Id. at 155 n.255 (“By one count, federal law in the United States includes at leasttwenty-two different definitions of ‘terrorism.’”); see also Nicholas J. Perry, TheNumerous Federal Definitions of Terrorism: The Problem of Too Many Grails, 30 J.LEGIS. 249, 254-69 (2004) (discussing the different definitions of terrorism at thefederal level).



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stantive criminal laws, such as TADA [Terrorist and Dis-ruptive Activities (Prevention) Act], POTA [Preventionof Terrorism Act], and UAPA [Unlawful Activities (Pre-vention) Act], which define terrorism—and other secur-ity-related offenses and establish special rules toadjudicate these offenses during non-emergencyperiods.42

“[O]n September 17, 2004 the Union Cabinet in keeping withthe UPA government’s Common Minimum Programme, approved ordi-nances to repeal the controversial . . . [POTA] and amend the UnlawfulActivities (Prevention) Act, 1967 [UAPA].”43 “By the promulgation of. . . Ordinance No. 1 of 2004, it repealed POTA.”44 “[W]hen the new[G]overnment [of India] repealed POTA, it simultaneously reenactedand thereby preserved several of its provisions as amendments to the[UAPA] of 1967.”45 In UAPA Sections 2(1)(o)-(p) 3-5, we find unlaw-ful activity and unlawful association defined and the provision “for ju-dicial review of designations of unlawful associations . . . .”46 In UAPASections 35-40, we find an incorporation of the terrorist organisationprovisions from POTA.47 Chapter IV of the UAPA, titled Punishmentfor Terrorist Activities, offers a clear, comprehensive, and plain lan-guage definition of terrorist act:

42 Kalhan et al., supra note 38, at 398-99; see also South Asian Terrorism Portal(SATP), The Terrorist and Disruptive Activities Prevention Act, 1987, http://satp.org/satporgtp/countries/india/document/actandordinances/Tada.htm (last visited Mar. 1,2009) (“[TADA] was permitted to lapse in May 1995 though cases initiated while itwas in force continue to hold legal validity.”); South Asian Terrorism Portal, TheUnlawful Activities Prevention Amendment Ordinance, 2004, http://www.satp.org/satporgtp/countries/india/document/actandordinances/the_unlawful_activities_amendord2004.htm [hereinafter The Unlawful Activities (Prevention) AmendmentOrdinance] (last visited Mar. 1, 2009) (“After the Prevention of Terrorism Act, 2002,was repealed through an Ordinance, the President of India, on September 21, 2004,promulgated an Ordinance to amend the Unlawful Activities (Prevention) Act,1967.”).43 Legal Service India, Repeal of POTA—Justified, http://www.legalservicesindia.com/articles/pota.htm (last visited Mar. 1, 2009).44 Legal Service India, Anti-Terrorism Laws in India & the Need of POTA, http://www.legalserviceindia.com/articles/anti_pota.htm (last visited Mar. 1, 2009).45 Kalhan et al., supra note 38, at 413.46 The Unlawful Activities (Prevention) Amendment Ordinance, supra note 43.47 Id.



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Whoever, with intent to threaten the unity, integ-rity, security or sovereignty of India or to strike terror inthe people or any section of the people in India or in anyforeign country, does any act by using bombs, dynamiteor other explosive substances or inflammable substancesor firearms or other lethal weapons or poisons or noxiousgases or other chemicals or by any other substances(whether biological or otherwise) of a hazardous nature,in such a manner as to cause, or likely to cause, death of,or injuries to any person or persons or loss of, or damageto, or destruction of, property or disruption of any sup-plies or services essential to the life of the community inIndia or in any foreign country or causes damage or de-struction of any property or equipment used or intendedto be used for the defence [sic] of India or in connectionwith any other purposes of the Government of India, anyState Government or any of their agencies, or detains anyperson and threatens to kill or injure such person in orderto compel the Government in India or the Government ofa foreign country or any other person to do or abstainfrom doing any act, commits a terrorist act.48

The United States Code (U.S. Code) contains a definition of ter-rorism.49 This law has embedded in it a requirement for the Secretaryof State to make annual country reports on terrorism to Congress:50

Definitions

As used in this section—

(1) the term “international terrorism” means terrorisminvolving citizens or the territory of more than 1 country;

(2) the term “terrorism” means premeditated, politicallymotivated violence perpetrated against noncombatanttargets by subnational groups or clandestine agents;

48 Id.49 See 22 U.S.C. § 2656f (2000 & Supp. 2006).50 See id. at 2656f(a).



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(3) the term “terrorist group” means any group practic-ing, or which has significant subgroups which practice,international terrorism;

(4) the terms “territory” and “territory of the country”mean the land, waters, and airspace of the country; and

(5) the terms “terrorist sanctuary” and “sanctuary” meanan area in the territory of the country—

(A) that is used by a terrorist or terrorist organization—

(i) to carry out terrorist activities, including training,fundraising, financing, and recruitment; or

(ii) as a transit point; and

(B) the government of which expressly consents to, orwith knowledge, allows, tolerates, or disregards such useof its territory and is not subject to a determinationunder—

(i) section 2405(j)(1)(A) of the Appendix to title 50;

(ii) section 2371(a) of this title; or

(iii) section 2780(d) of this title.51

Aside from law, U.S. defense and law enforcement policies in-clude definitions of terrorism which are harmonious with, but do notmirror, U.S. law. The U.S. Department of Defense defines terrorism as“[t]he calculated use of unlawful violence or threat of unlawful violenceto inculcate fear; intended to coerce or to intimidate governments orsocieties in the pursuit of goals that are generally political, religious, orideological.”52

In contrast, the U.S. Federal Bureau of Investigation (FBI), re-sponsible for domestic law enforcement and aspects of domestic

51 Id. at §2656f(d).52 U.S. Department of Defense Dictionary of Military and Associated Terms,Terrorism, http://www.dtic.mil/doctrine/jel/doddict/data/t/05461.html (last visitedMar. 1, 2009).



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counterterrorism, “divides the terrorist threat facing the United Statesinto two broad categories, international and domestic.”53

III. POTENTIAL AGROTERRORIST OR ECOTERRORIST GOALS

The U.S. National Defense University’s Center for Counter-proliferation Research commissioned Dr. W. Seth Carus to study andopine upon bioterrorism and biocrimes, necessarily including the cate-gories of agroterrorism and ecoterrorism considered in this article.54 Dr.Carus categorized potential goals for ecoterrorists as employing agentswith unique cause and effect, noting a special attraction to biologicalweapons because “pathogens could cause mass casualties on an unprec-edented scale.”55 Dr. Carus further commented on the curious omissionfrom official definitions of any reference to “groups with apocalypticvisions who are uninterested in influencing governments and seek in-stead to inflict mass casualties.”56 In contrast to traditional terroristsusing violence as a means to an end, Dr. Carus hypothesizes that “pro-ponents of catastrophic terrorism view mass killing as the desired end.Groups of this type are not common, yet they do exist.”57

Biotoxins and infectious diseases have been sporadicallyweaponized throughout history.58 What aspects of biological weapons

53 Jarboe, supra note 4 (The FBI’s definition states that “International terrorisminvolves violent acts or acts dangerous to human life that are a violation of thecriminal laws of the United States or any state, or that would be a criminal violation ifcommitted within the jurisdiction of the United States or any state. Acts ofinternational terrorism are intended to intimidate or coerce a civilian population,influence the policy of a government, or affect the conduct of a government. Theseacts transcend national boundaries in terms of the means by which they areaccomplished, the persons they appear intended to intimidate, or the locale in whichperpetrators operate.”).54 See W. SETH CARUS, BIOTERRORISM AND BIOCRIMES: THE ILLICIT USE OF

BIOLOGICAL AGENTS SINCE 1900, at v (rev. 2001) (cited with authority in TERRY

KNOWLES ET AL., NAT’L INST. OF JUSTICE, DEFINING LAW ENFORCEMENT’S ROLE IN

PROTECTING AMERICAN AGRICULTURE FROM AGROTERRORISM 29-31 (2005), availableat http://www.ncjrs.gov/pdffiles1/nij/grants/212280.pdf)).55 Id. at 3.56 Id.57 Id.58 J.P. Dudley & M.H. Woodford, Bioweapons, Bioterrorism and Biodiversity:Potential Impacts of Biological Weapons Attacks on Agricultural and Biological



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would prove attractive to terrorists, aside from the intended psychologi-cal impact? Dr. Carus believes that bioterrorists might well use biologi-cal agents as a “tool for achieving specialized objectives not necessarilyintended to directly influence government actions,” especially where theelements of surprise and concealed origins might magnify the effects ofthe attack.59

Leading specialists considered the results of failure to detect orcontain disease outbreaks stemming from agroterrorism and ecoterror-ism. As the chairman of the World Organisation for Animal HealthWorking Group on Wildlife Diseases cautioned, consequences could in-clude “severe erosion of genetic diversity in local and regional popula-tions of both wild and domestic animals, the extinction of endangeredspecies and the extirpation of indigenous peoples and their cultures.”60

Shortly after the events of September 11, 2001, the Congres-sional Research Service (CRS) offered the U.S. Congress a clearlystated and unclassified report titled Agroterrorism: Options in Con-gress.61 Alejandro Segarra opined in the report that the goal of agroter-rorism is to “cripple the biological infrastructure of a nation’sagriculture, i.e., its livestock and its crops. Many links in the agricul-tural production chain are potentially susceptible to attack with a bio-logical weapon.”62 Prevention being preferable to cure, Segarra notestraditional defense against the introduction of livestock or plant dis-eases has been “try[ing] to keep them out of the country by stoppingthem at our borders.”63 Failing that, the next line of defense will “de-

Diversity, REV. SCI. TECH. OFF. INT’L. EPIZOOTIES, at 125 (2002), available at http://www.oie.int/boutique/extrait/jpdudley.pdf?PHPSESSID=392cd0b95223fe1dab1d2a961e187e6d.59 Carus, supra note 55, at 3. Carus believes that “[v]irtually all bioterrorists seek tokeep their use of biological agents a secret, because in many instances successdepended on the lack of appreciation that a disease outbreak was intentional.”60 Id.61 ALEJANDRO E. SEGARRA, CONGRESSIONAL RESEARCH SERVICE, AGROTERRORISM:OPTIONS IN CONGRESS (2001), available at http://www.law.umaryland.edu/marshall/crsreports/crsdocuments/RL31217_12192001.pdf.62 Id. at summary.63 Id.



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pend on quick actions from alert and informed farmers and diseasespecialists.”64

Segarra’s CRS report went further to define and predict twotypes of potential agroterrorism effects: Direct economic losses due tothe “cost of destroying disease-ridden crops and livestock, and the costof disease containment[;]”65 and indirect costs and multiplier effects re-sulting from disorder in agricultural sectors relying on agriculture(transportation and retail) and from the loss of export markets (tradingpartners embargoing particular U.S. agricultural products).66 The pre-sent-day costs of preventing and combating agroterrorism and ecoterror-ism can be found in Appendix 2 of this article titled: HomelandSecurity Funding for Agriculture, by Source.

Jim Monke of the CRS observed that “the general susceptibilityof the agriculture and food industry to [agroterrorism (in the guise ofbiological vector propagated bioterrorism)] is difficult to address in asystematic way due to the geographically dispersed, yet industriallyconcentrated nature of the industry, and the inherent biology of growingplants and raising animals.”67 While focused on potential threats toAmerican agriculture, his warnings hold similar applicability to variousIndian agricultural endeavors.68

The Council on Foreign Relations (CFR)69 quoted former U.S.Secretary of Health and Human Services Tommy Thompson as sayingin November 2001 he was “particularly concerned about food-relatedterrorism, which could involve either attempts to introduce poisons intothe food supply or attacks that would ruin domestically cultivated cropsor livestock.”70 According to the U.S. Centers for Disease Control and

64 Id.65 Id. at 2.66 Id. at 2-3.67 MONKE, supra note 3, at 2.68 Id. at 1-2.69 The Council on Foreign Relations touts itself as a nonpartisan resource forinformation and analysis. Council on Foreign Relations, Mission Statement, http://www.cfr.org/about/mission.html (last visited Mar. 1, 2009).70 Targets for Terrorism: Food and Agriculture, COUNCIL ON FOREIGN REL., January2006, http://www.cfr.org/publication/10197/targets_for_terrorism.html#1 [hereinafterTargets for Terrorism] (internal quotations omitted).



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Prevention, America “spends more than [one billion dollars] every yearto keep America’s food supply safe, but even without terrorism, food-borne diseases cause about 5,000 deaths and 325,000 hospitalizationseach year . . . .”71 Agroterrorism expert Cain asserts:

The experts agree on one thing. The cost in terms ofdamages is directly proportional to the time it takes todiagnose the disease. The longer it takes to diagnose adisease, the more it could spread and cause potentiallyextensive losses of production and exports due to sanc-tions against the U.S.72

The CFR predicted that “[i]mported food could be tainted withbiological or chemical agents before entering the United States, or tox-ins could be introduced at a domestic food-processing plant.”73 TheCFR further stated that “[c]rops or livestock raised on American soilcould also be targeted. Experts worry that terrorists might try to spreadfalse rumors about unsafe foods via the mass media or the Internet.”74

Attempted agroterrorist attacks worldwide included a 1970s Pal-estinian plot to contaminate Jaffa oranges with mercury; the CFR re-ports that Israel’s citrus exports decreased by forty percent, and a 1989incident of cyanide contamination in Chilean grapes cost Chile two hun-dred million dollars in lost trade.75 A successful attack on Americanlivestock might cause between ten and thirty billion dollars in damageto the national economy, opined the CFR.76 Such a prediction is plausi-ble since the foot-and-mouth disease outbreak that occurred in Canadabetween 1951 and 1953 cost two million dollars to destroy the animals,decreased livestock value by six hundred and fifty million dollars, andcaused an embargo which cost two billion dollars.77 Anne Kohnen

71 Id.72 CAIN, supra note 28, at 2 (internal footnotes omitted).73 Targets for Terrorism, supra note 71.74 Id.75 Id.76 Id.77 ANNE KOHNEN, JOHN F. KENNEDY SCH. OF GOV’T, HARVARD UNIV., RESPONDING

TO THE THREAT OF AGROTERRORISM: SPECIFIC RECOMMENDATIONS FOR THE UNITED

STATES DEPARTMENT OF AGRICULTURE 4 (2000), available at http://belfercenter.ksg.harvard.edu/files/responding_to_the_threat_of_agroterrorism.pdf.



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noted while crops can become resistant to “diseases through genetic se-lection and production of resistant strains[,]”78 foreign animal diseases(FADs) pose the greatest threat to agriculture because animals have nobuilt up immunity against them (or cannot build up immunity), and mayrequire drastic quarantine and immediate eradication efforts.79

There is not common agreement as to the numbers and locationsof agroterrorism and ecoterrorism, and at the time of this article’s writ-ing, there were no clearly identifiable instances of agroterrorism orecoterrorism in India written about in India’s open (unclassified)sources of information.80 There are at least six groups that committedterroristic acts in or against India that could (but hopefully will not)undertake agroterrorism or ecoterrorism.

Of most recent note and infamy, Lashkar-e-Taiba (LeT) (Armyof the Pure), is the group likely responsible for the December 2008 co-ordinated terrorist attacks on civilians in Mumbai, India.81 LeT is de-scribed as “a militant Islamist group operating in Pakistan as well as inJammu and Kashmir” with “ideological, but unconfirmed operationalties to al-Qaeda,” with likely responsibility “for some of the most high-profile terrorist attacks in India, also including the July 11, 2006 bomb-ing of the Mumbai commuter rail.”82

In Jammu and Kashmir’s spectacularly picturesque high altitudegrounds of confrontation, at least four terrorist-insurgent groups oper-

78 Id. at 19.79 Id. at 12-13.80 For a comprehensive, unclassified description of groups that committed terroristicacts against India, see, e.g., Eben Kaplan & Jayshree Bajoria, Counterterrorism inIndia, COUNCIL ON FOREIGN REL., http://www.cfr.org/publication/11170/counterterrorism_in_india.htm (last visited Mar. 1, 2009).81 Schmitt, Eric; Sengupta, Somini (2008-12-03). “Ex-U.S. Official Cites PakistaniTraining for India Attackers,” The New York Times. Retrieved on 3 December 2008.Pakistan’s National Security national security adviser, Mahmud Ali Durrani,confirmed that the lone surviving gunman from the Mumbai terrorist attacks,Muhammad Ajmal Kasab, is a Pakistani citizen; Durrani was then dismissed by thePakistani Prime Minister over this disclosure. See Oppel, Richard A (2009-01-07)Gunman in Mumbai Siege a Pakistani, New York Times, http://www.nytimes.com/2009/01/08/world/asia/08pstan.html?_r=1&adxnnl=1&adxnnlx=1232650806-BGjldVINLve708RfexRVrw (last visited Mar. 1, 2009).82 Id.



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ate. Those groups include: Jaish-e-Muhammad (Army of Moham-med);83 Harakat ul-Mujahedeen (HuM) (Islamic Freedom Fighters’Group), “founded . . . as an anti-Soviet group fighting in Afghanistan”which “shifted its focus to Jammu and Kashmir” and terrorist operationsin Bosnia-Herzegovina, Myanmar, and Tajikistan;84 Harakat ul-Jihad-I-Islami (HUJI), founded to fight Soviets, but more recently “concen-trated its efforts in Jammu and Kashmir. HUJI . . . is based in Pakistanand Kashmir . . .”85and; Jamiat ul-Mujahedin, “a small group of pro-Pakistan Kashmiri separatists[,]” “thought to be responsible for a pair of2004 grenade attacks against political targets in India.”86

Finally, two revolutionary-oriented terrorist-insurgent groups inIndia include: the Communist Party of India, comprised of leftist mili-tants, broke down seeking a “‘revolutionary zone’ of control extendingfrom the Nepalese border down to the southern part of AndhraPradesh,”87 and the United Liberation Front of Assam (ULFA), seekingan “independent socialist state in Assam” and is known for “attacks onpolitical leaders, security forces, and infrastructure.”88

Regarding threats worldwide, but concerning the U.S. in particu-lar, the James Martin Center For Nonproliferation Studies (CNS) at theMonterey Institute of International Studies, indicates that since 1915,there were twenty-three acts of agroterrorism around the world, sevenof which took place in the U.S.89 Dr. Carus, the Deputy Director of theCenter for the Study of Weapons of Mass Destruction, found in con-trast, that since the turn of the twentieth century, there were twelve“documented cases involving biological agents used against agricultureand food sources” and numerous violent acts and threatened acts in-tended to have an ecological effect.90 Dr. Carus reviewed “every identi-

83 Id.84 Id.85 Id.86 Id.87 Id.88 Id.89 See generally James Martin Center for Nonproliferation Studies, Chronology ofCBW Incidents Targeting Agriculture and Food Systems 1915-2006, http://www.cns.miis.edu/cbw/agchron.htm (last visited Mar. 1, 2009) (listing the acts ofagroterrorism between 1915 and 2006).90 KNOWLES ET AL., supra note 55, at 29.



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fiable instance in open-source materials in which a perpetrator(s) used,acquired, or threatened to use a biological agent” and “researched over270 alleged cases involving biological agents but identified only 12cases that involved agriculture and/or food sources.”91

Year Bioterrorism Incident Alleged Perpetrators1997 Hemorrhagic virus spread among wild rabbit New Zealand farmers

population in New Zealand1996 Food poisoning using shigella in a Dallas, Texas hospital lab employee

hospital1995 Food poisoning of an estranged husband using Kansas physician

ricin in Johnson County, Kansas1984 Food poisoning of public salad bars using Rajneeshee Cult

salmonella in The Dalles, Oregon1970 Food poisoning of four college roommates using college roommate

parasite-contaminated food1964 Food poisoning in Japan using salmonella and Japanese physician

dysentery1952 African milk bush used to kill 33 head of Mau Mau insurgents

livestock in Kenya1939 Food poisoning in Japan using pastries Japanese physician

contaminated with salmonella1936 Food poisoning in Japan using cakes contaminated Japanese physician

with salmonella1916 Food poisoning in New York City using arsenic to New York dentist

kill wife’s parents1913 Food poisoning in Germany using cholera and German chemist

typhus to kill family members1912 Food poisoning in France using salmonella and French druggist

poisonous mushroomsSource: Carus, 2002; Chalk, 2004.92

There is some dispute as to which of the twelve incidents couldbe termed as completed (versus inchoate or not yet made complete, cer-tain, or specific) acts of terrorism.93 “The first occurred in Kenya in1952, when a group of Mau Mau insurgents” opposing British rule inKenya poisoned thirty-three steers, cutting their hides and introducingAfrican milk bush latex into their systems to kill eight of the animals.94

91 Id.92 Id. at 30.93 See id. at 29 (“Only [two] of the [twelve] incidents could be termed as acts ofterrorism.”).94 Id.



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The second bioterrorism attack Dr. Carus identified “occurred in 1984,when the Rajneeshee Cult [caused] . . . [a] total of 751” nonfatal injuriesresulting from a terror effort to “make people sick so they could notvote” by contaminating “public restaurants (salad bars, coffee creamers,and salad dressing) with salmonella in The Dalles, Oregon.”95

96

Curiously omitted from this study, however, were the twenty-three U.S. (nineteen confirmed, four suspected) Bacillus anthracis (an-thrax) outbreak incidents during the latter part of 2001 and early 2002.97

“[N]o transmission from infected to susceptible persons . . . linked onecase with another[,]” but rather arose because “a terrorist or terroristssent . . . anthrax spores through the” U.S. Mail.98 The CDC’s report

95 Id. at 30 (internal quotations omitted).96 UCLA Department of Epidiomology, American Anthrax Outbreak of 2001, http://www.ph.ucla.edu/epi/Bioter/detect/antdetect_intro.html (last visited Mar. 1, 2009).97 See id. (discussing the 2001 anthrax outbreak).98 Id.



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found that “in October 2001, the first inhalational anthrax case in theUnited States since 1976 was identified in a media company worker inFlorida.”99 As a result of the national investigation to identify addi-tional cases and determine possible exposures to Bacillus anthraci, theCDC discovered that “[f]rom October 4 to November 20, 2001, 22cases of anthrax (11 inhalational, 11 cutaneous) were identified; 5 of theinhalational cases were fatal.”100 Twenty of those 22 (91%) case-pa-tients were either “mail handlers or were exposed to worksites wherecontaminated mail was processed or received.”101 “B. anthracis isolatesfrom four powder-containing envelopes, 17 specimens from patients,and 106 environmental samples were indistinguishable by molecularsubtyping.”102

103

99 Daniel B. Jernigan et al., Investigation of Bioterrorism-Related Anthrax, UnitedStates, 2001: Epidemiologic Findings, EMERGING INFECTIOUS DISEASES, Oct. 2002, at1019, available at http://www.cdc.gov/ncidod/EID/vol8no10/pdf/02-0353.pdf.100 Id. at 1019.101 Id. The CDC’s additional findings were that “[i]llness and death occurred not onlyat targeted worksites, but also along the path of mail and in other settings. Continuedvigilance for cases is needed among health-care providers and members of the publichealth and law enforcement communities.”102 Daniel B. Jernigan et al., Investigation of Bioterrorism-Related Anthrax, UnitedStates, 2001: Epidemiologic Findings, EMERGING INFECTIOUS DISEASES, Oct. 2002, at1019, available at http://www.cdc.gov/ncidod/EID/vol8no10/pdf/02-0353.pdf.103 Id. at 1023.



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The “CDC informed the public in many ways, occasionally viainterviews with reporters, other times in talks or professional presenta-tions, but most often with updates in the Morbidity and MortalityWeekly Report (MMWR)” from 2001 through 2003.104 As for the ensu-ing law enforcement investigation—code-named “Amerithrax” by theU.S. FBI and its partners—the hunt for the Anthrax attack culprits be-came “one of the largest and most complex in the history of law en-forcement.”105 As an epilogue, in the Fall of 2008, both the FBI andDepartment of Justice made breakthroughs in the case, releasing docu-ments and information tying a defense bioweapons expert (Dr. BruceIvins) to the incidents,106 but the suspect committed suicide beforecharges were filed.107

“According to U.S. law enforcement, radical environmentalismcurrently poses the most visible homegrown threat to the national secur-ity of the United States.”108 The RAND Center for Terrorism RiskManagement Policy studied this radical environmentalism, finding it“covers an eclectic range of individuals and causes, although most findexpression and representation in the Earth Liberation Front (ELF).”109

Contemporary radical environmentalism’s two foci are: “‘Biocentrism’which regards all living organisms on earth as equal and deserving ofmoral rights and respect, [and] ‘Deep ecology’ which calls for a generalrollback of civilization and industrialization, the removal of pathogenicspecies (including, presumably, rapacious humans), and the restorationof the ecological balance.”110

The RAND Corporation estimates that the highly decentralizedELF extremist entity “caused between $35 million and $45 million indirect property damage, operating in a geographic arc” from Washing-ton, Oregon, California, Arizona, New York, Minnesota, Pennsylvania,

104 UCLA Department of Epidemiology School of Public Health, supra note 97.105 AMERITHRAX Investigation, Federal Bureau of Investigation Website, Ahttp://www.fbi.gov/anthrax/amerithraxlinks.htm (last visited Mar. 1, 2009).106 Id.107 Shane, Scott, and Lichtblau, Eric, Scientist’s Suicide Linked to Anthrax Inquiry,New York Times Aug. 2, 2008, http://www.nytimes.com/2008/08/02/washington/02anthrax.html.108 CHALK, supra note 5, at 47.109 Id. at 47.110 Id.at 48.



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and Indianapolis from 1994 through 2005.111 “Radical environmental-ists have used a variety of tactics in the name of ecological protection,all of which the FBI designate as examples of ‘special interest terror-ism.’”112 Such incidents, and the U.S. or multinational groups claimingcredit or being investigated for the commission of such incidents, in-clude but are not limited to the six notable groups.

Attacks targeting foresty resources are the modus operandi fortwo groups in particular. Earth First! orchestrated attacks, protests, andcivil disobedience from 1984 onward, specializing in “‘tree spiking’(insertion of metal or ceramic spikes in trees in an effort to damagesaws) as a tactic to thwart logging.”113 As some members chose tomainstream Earth First!, others still refused to abandon criminal acts asa tactic, and in turn established the Earth Liberation Front (ELF) in1992 in Brighton, England.114 The ELF advocates monkeywrenching or“acts of sabotage and property destruction against industries and otherentities perceived to be damaging to the natural environment.”115 Thisincludes “tree spiking, arson, sabotage of logging or construction equip-ment, and other types of property destruction.”116

The so-called Animal Liberation Front (ALF), formed in the late1970s in the United Kingdom, is believed to have worked together withELF to commit “more than 600 criminal acts in the United States since1996, resulting in damages in excess of 43 million dollars.”117 In partic-ular, ALF’s direct action targeting of fur companies, mink farms, res-taurants, and animal research laboratories has been intended to “causeeconomic loss or to destroy the victims’ company operations.”118

The Sea Shepherd Conservation Society, formed by disaffectedmembers of the ecological preservation group Greenpeace, is another

111 Id. at 47-48.112 Id. at 49 (internal citations omitted).113 Jarboe, supra note 4, at 1.114 Id. at 1.115 Id.116 Id. at 2-3.117 Id.118 Id. at 2.



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splinter group of radical environmentalists. Since 1977 Greenpeace at-tacked the fishing industry by cutting commercial fishing drift nets.119

Finally, two groups with a southwestern area of focus attackedpublic utilities and private entities equally. The Coalition to Save thePreserves (CSP), in the Phoenix, Arizona area, committed arson attackson new homes under construction, causing more than $5 million indamages.120 The self-proclaimed Evan Mecham Eco-Terrorist Interna-tional Conspiracy, named after a former Arizona governor and car deal-ership owner, coincidentally has initials EMETIC, a word that meanssomething that induces vomiting.121 EMETIC was “formed to engagein eco-terrorism against nuclear power plants and ski resorts in thesouthwestern United States.”122 Amongst its various claimed attacks, inNovember 1987 EMETIC claimed responsibility for damage to a chair-lift at the Fairfield Snow Bowl Ski Resort near Flagstaff, Arizona, and“planned incidents at the Central Arizona Project and Palo Verde nu-clear generating stations in Arizona; the Diablo Canyon Nuclear Facil-ity in California; and the Rocky Flats Nuclear Facility in Colorado.”123

The RAND Corporation expects to see “militant ecologists . . .assum[ing] an increasingly prominent role in civil disobedience directedagainst perceived symbols of global capitalism and corporate greed, po-tentially leading the call for targeted aggression in the name of anti-humanist and anarchist ideals” in major urban U.S. centers which areloci for “politico-economic power or play host to prominent conglomer-ate interests . . . .”124

119 Id.120 Id. at 3.121 Terrorist Organization Profile: Evan Mecham Eco-Terrorist InternationalConspiracy (EMETIC), START-National Consortium for the Study of terrorism andResponses to Terrorism Website, http://www.start.umd.edu/data/tops/terrorist_organization_profile.asp?id=3239 (last visited Mar. 1, 2009).122 Id.123 Id.124 CHALK, supra note 5, at 52.



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IV. PREVENTING AN AGROTERRORIST OR ECOTERRORIST

ATTACK: A CONCERTED APPROACH

Past agroterrorism and ecoterrorism attacks indicate the neces-sity for active defense (countering terrorism) as well as an active of-fense (counterterrorism).

Indian political expert B. Raman noted that “[u]nder India’s fed-eral Constitution, the responsibility for policing and maintenance of lawand order is that of the individual states.”125 Raman observed that thefederal, central government in New Delhi can “only give [the individualstates] advice, financial help, training and other assistance to strengthentheir professional capabilities and share with them the intelligence col-lected by it. The responsibility for follow-up action lies with the statepolice.”126 At the federal, central level, India’s counterterrorism capa-bilities include a superbly competent interagency approach, combiningpolitical, military, and police organizations within the government ofIndia.127

The Indian Ministry of Home Affairs, for which the U.S.equivalent would be the Department of Homeland Security, includes theIntelligence Bureau (IB) which oversees national police, paramilitaries,and domestic intelligence gathering. Raman’s assessment of the IB isthat it “oversees an interagency counterterrorism center similar” to therole formerly played by the U.S. Central Intelligence Agency (CIA),and now assumed by the Director of National Intelligence (DNI).128

Also overseeing its own counterterrorism force, the Ministry of ExternalAffairs is akin to the U.S. State Department’s Bureau of DiplomaticSecurity.129 In the past, the Ministry of External Affairs has “oversee[n]

125 B. Raman, Pakistan Weaves an Elaborate Web, ASIA TIMES ONLINE, Jan. 19,2005, http://www.atimes.com/atimes/South_Asia/GA19Df03.html. Raman is theDirector of the Institute for Topical Studies, Chennai, and served as additionalsecretary (retired), and cabinet secretariat, government of India, New Dehli.126 B. Raman, India’s Counter-terrorism Strategy, REDIFF SPECIAL, Apr. 6, 2003,http://www.rediff.com/news/2003/apr/05spec.htm [hereinafter India’s Counter-terrorism Strategy].127 See Kaplan & Bajoria, supra note 81, at 3-5.128 Id. at 4.129 See, e.g., U.S. Deparment of State–Bureau of Diplomatic Security Website, http://www.state.gov/m/ds/ (last visited Mar. 1, 2009).



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diplomatic counterterrorism functions such as briefing other nations onsuspected Pakistani sponsorship of terrorism in India.”130

Finally, the Indian Armed Forces and police exercise considera-ble counterterrorism capabilities. In particular, the Indian Army under-takes “counterterrorism operations as a last resort, though in Jammu andKashmir they play a more consistent role.”131 The State-run policeforces (like the 165,000 force Central Reserve Police Force), includes“special security forces to guard airports and other high-profile targets,and paramilitary forces that patrol the borders and assist the policewhen necessary.”132

The U.S. Government makes a distinction between counterter-rorism and antiterrorism.133 Counterterrorism generally refers to offen-sive military operations designed to prevent, deter, and respond toterrorism.134 In contrast, antiterrorism consists of defensive measurestaken to reduce the vulnerability of individuals and property to terroristattacks.135 The U.S. Department of Defense (DoD) “is not the leadagency for combating terrorism,” but the department has significant re-sponsibilities and roles in it.136 However, DoD plays an important sup-porting role, “providing technical assistance or forces when requestedby the President of the U.S. and/or the Secretary of Defense.”137 Aside

130 Id.131 Id. at 2.132 Id. at 3-4; see also India’s Counter-terrorism Strategy, supra note 127 (explainingIndia’s counterterrorism policies and techniques).133 LTC BAIME, EUGENE ET AL., THE JUDGE ADVOCATE GEN.’S LEGAL CTR. & SCH.,OPERATIONAL LAW HANDBOOK 400 (Maj Derek L. Grimes et al. eds., 2006), availableat http://www.au.af.mil/au/awc/awcgate/law/oplaw_hdbk.pdf.134 Id. at 401.135 Id.136 Id.137 Id. Please note that in the U.S., Counterterrorism (CT)

generally refers to offensive military operations designed to prevent,deter and respond to terrorism. It is a highly-specialized, resource-intensive military activity. . . . [O]perations forces units are preparedto execute these missions on order of the President or SECDEF.Combatant commanders maintain designated CT contingency forceswhen national assets are not available. These programs aresensitive, normally compartmented, and addressed in relevantNational Security Directives (NSD), Presidential DecisionDirectives (PDD), National Security Presidential Directives



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from U.S. Government plans, orders, and directives not subject to pub-lic scrutiny due to their classification or compartmentation, unclassifiedU.S. Homeland Security Presidential Directives are issued by the Presi-dent on matters pertaining to homeland security.138 Specifically, terror-ism threats of all kinds (not just agroterrorism and ecoterrorism) areconsidered, including:

• HSPD – 1: Organization and Operation of the Home-land Security Council. Ensures coordination of allhomeland security-related activities among executivedepartments and agencies and promote the effectivedevelopment and implementation of all homeland se-curity policies.

• HSPD – 2: Combating Terrorism Through Immigra-tion Policies. Provides for the creation of a task forcewhich will work aggressively to prevent aliens whoengage in or support terrorist activity from entering theUnited States . . . .

• HSPD – 3: Homeland Security Advisory System. Es-tablishes a comprehensive and effective means to dis-seminate information regarding the risk of terrorist acts

(NSPD), contingency plans (CONPLAN) and other classifieddocuments.

Id. Antiterrorism (AT), which is sometimes interchangeably used with the termcombating terrorism,

consists of defensive measures to reduce the vulnerability ofindividuals and property to terrorist attacks. Overseas (OCONUS),AT should be an integrated and comprehensive plan within eachcombatant command. The AT plan is normally thought of in twoprimary phases: proactive and reactive. The proactive phaseincludes planning, resourcing and taking preventive measures, aswell as preparation, awareness, education and training, prior to anincident. The reactive phase includes the crisis management actionsin response to an attack. In the continental United States (CONUS),DoD’s role is generally that of providing expert technical support inthe area of consequence management.

Id.138 Author’s note: At the time of this article’s writing, the new administration underPresident Obama had not issued new, unclassified Homeland Security policy, noraltered previous policy pertinent to the topics discussed in this article.



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to Federal, State, and local authorities and to theAmerican people.

• HSPD – 4: National Strategy to Combat Weapons ofMass Destruction. Applies new technologies, in-creased emphasis on intelligence collection and analy-sis, strengthens alliance relationships, and establishesnew partnerships with former adversaries to counterthis threat in all of its dimensions.

• HSPD – 5: Management of Domestic Incidents. En-hances the ability of the United States to manage do-mestic incidents by establishing a single,comprehensive national incident management system.

• HSPD – 6: Integration and Use of Screening Informa-tion. Provides for the establishment of the TerroristThreat Integration Center.

• HSPD – 7: Critical Infrastructure Identification, Pri-oritization, and Protection. Establishes a national pol-icy for Federal departments and agencies to identifyand prioritize United States critical infrastructure andkey resources and to protect them from terroristattacks.

• HSPD – 8: National Preparedness. Identifies steps forimproved coordination in response to incidents. Thisdirective describes the way Federal departments andagencies will prepare for such a response, includingprevention activities during the early stages of a terror-ism incident. This directive is a companion to HSPD-5.. . . .

• HSPD – 9: Defense of United States Agriculture andFood. Establishes a national policy to defend the agri-culture and food system against terrorist attacks, majordisasters, and other emergencies.



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• HSPD – 10: Biodefense for the 21st Century. Pro-vides a comprehensive framework for our nation’sBiodefense.

• HSPD – 11: Comprehensive Terrorist-Related Screen-ing Procedures. Implements a coordinated and com-prehensive approach to terrorist-related screening thatsupports homeland security, at home and abroad. Thisdirective builds upon HSPD – 6.

• HSPD – 12: Policy for a Common Identification Stan-dard for Federal Employees and Contractors. Estab-lishes a mandatory, Government-wide standard forsecure and reliable forms of identification issued bythe Federal Government to its employees and contrac-tors (including contractor employees).

HSPD – 13: Maritime Security Policy. Establishespolicy guidelines to enhance national and homelandsecurity by protecting U.S maritime interests . . . .

• HSPD - 16: Aviation Strategy. Details a strategic vi-sion for aviation security while recognizing ongoingefforts, and directs the production of a National Strat-egy for Aviation Security and supporting plans.. . . .

• HSPD – 18: Medical Countermeasures against Weap-ons of Mass Destruction. Establishes policy guidelinesto draw upon the considerable potential of the scien-tific community in the public and private sectors to ad-dress medical countermeasure requirements relating toCBRN threats.. . . .

• HSPD – 20: National Continuity Policy. Establishes acomprehensive national policy on the continuity offederal government structures and operations and asingle National Continuity Coordinator responsible forcoordinating the development and implementation offederal continuity policies.



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. . . .

• HSPD – 21: Public Health and Medical Preparedness.Establishes a national strategy that will enable a levelof public health and medical preparedness sufficient toaddress a range of possible disasters.139

Towards that end, U.S. Homeland Security Presidential Direc-tive 10 of April 2004 defines prevention and protection as one of theessential pillars of the U.S. response to the terrorist threat.140 The fouressential pillars of the U.S. response to the terrorist threat are: “ThreatAwareness, Prevention and Protection, Surveillance and Detection, andResponse and Recovery.”141

At the behest of the President of the U.S., assets under theHomeland Security Council (HSC) are organized under the HSC Princi-pals Committee (HSC/PC) to be the “senior interagency forum underthe HSC for homeland security issues.”142 Pursuant to Homeland Se-curity Presidential Directive 1, October 29, 2001, on the Organizationand Operation of the Homeland Security Council, the HSC/PC is com-posed of the following members:

[T]he Secretary of the Treasury; [T]he Secretary of De-fense; [T]he Attorney General; [T]he Secretary of Healthand Human Services; [T]he Secretary of Transportation;[T]he Director of the Office of Management and Budget;[T]he Assistant to the President for Homeland Security(who serves as Chairman); [T]he Assistant to the Presi-dent and Chief of Staff; [T]he Director of Central Intelli-

139 Department of Homeland Security, Homeland Security Presidential Directives(HSPDs), available at http://www.dhs.gov/xabout/laws/editorial_0607.shtm. See alsoLTC EUGENE BAIME, ET AL., supra note 134, at 411-13 for a brief, clear outline ofassets used in combating terrorism and counterterrorism.140 The White House, Biodefense for the 21st Century, http://www.whitehouse.gov/homeland/20040430.html (last visited Oct. 16, 2008).141 Id.; see also REYNOLDS M. SALERNO & LAUREN T. HICKOK, BIOSECURITY AND

BIOTERRORISM: BIODEFENSE STRATEGY, PRACTICE, AND SCIENCE 107-116 (2007),available at http://www.liebertonline.com/doi/abs/10.1089/bsp.2006.0027.142 U.S. Homeland Security Presidential Directive—1, 37 PUB. PAPERS 44 (Nov. 5,2001), available at http://www.whitehouse.gov/news/releases/2001/10/20011030-1.html.



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gence; [T]he Director of the Federal Bureau ofInvestigation; [T]he Director of the Federal EmergencyManagement Agency; and [T]he Assistant to the Presi-dent and Chief of Staff to the Vice President. The Assis-tant to the President for National Security Affairs invitedto attend all meetings of the HSC/PC.143

With so many policy documents and so many objectives, forpurposes of this article, I believe that the recurrent common themes andrequirements regarding counterterrorism and antiterrorism measures forthe U.S. and India should focus on a three-pronged, combined, and in-teragency approach, as adapted from Knowles, to preventing agroter-rorist and ecoterrorist attacks.

1. Define in advance the role of law enforcement, mili-tary, and judiciary in regard to these acts of terrorism;

2. Establish a common understanding and operationalpicture through shared intelligence on threats and vulner-ability of industry, agriculture, and other aspects of pub-lic and private sectors;

3. Delineate responsibilities for protecting vulnerabili-ties, preventing and responding to attacks, continuity ofoperations, and hand off, where necessary.144

Special FBI Agent David Cudmore says, “[i]dentifying threatsof agroterrorism and stopping them before they happen are obviouslyvital roles for law enforcement.” Cudmore, a weapons of mass destruc-tion coordinator, adds,

But protecting the Nation’s agricultural industry willtake combined efforts of the agriculture industry, govern-ment, law enforcement, and academic and scientific

143 Id.144 See KNOWLES ET AL., supra note 55, at 15 (listing the challenges for lawenforcement in dealing with agroterrorism).



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communities working together to minimize both the like-lihood of an attack and the severity of its impact.145

Local law enforcement should gather intelligence, for ex-ample, by working with livestock producers to identifyvulnerable farms and feedlots. Partnerships—the bestway to prevent an occurrence of agroterrorism and theonly way to contain one—must be created among the lo-cal sheriff and farmers, ranchers, meatpackers, truckers,feedlot owners, and other critical members of the food-supply chain in the jurisdiction. Meetings with localchapters of livestock associations and other industrygroups can encourage the exchange of ideas. Also, locallaw enforcement must establish a working relationshipwith veterinarians and animal and plant healthinspectors.146

Mr. Glenn R. Schmitt, “director of the Office of Research andData at the U.S. Sentencing Commission and the former acting director”of the U.S. Department of Justice’s NIJ, aptly notes that “agroterrorismis not meant to be an act of violence against livestock but an attack onthe economic stability of the [nation].”147

The study funded by NIJ identified five groups that could posethreats to our agricultural industry:

1. International terrorists. (Although many animal dis-eases have been eradicated in this country, they flourishoverseas. The foot-and-mouth virus is easily accessed,transported, and transmitted.)

2. Domestic terrorists, including anarchist or an-tigovernment groups.

3. Militant animal rights groups.

145 GLENN R. SCHMITT, Agroterrorism—Why We’re Not Ready: A Look at the Role ofLaw Enforcement, NAT’L INST. JUST. J., June 2007, available at http://www.ojp.usdoj.gov/nij/journals/257/agroterrorism.html.146 Id.147 Id.



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4. Economic opportunists seeking financial gain as aresult of a change in market prices.

5. Disgruntled employees seeking revenge.148

“The paradigm for protecting the [U.S.] changed after [Septem-ber 11, 2001] . . . ,” from preventing an agroterrorist or ecoterroristattack to focusing on a multiechelon, concerted, and coordinated inter-agency effort.149 Aside from classified and unclassified U.S. DoDcounterterrorism and countering terrorism assets, the U.S. Departmentof Homeland Security (DHS) maintains information on potential terror-ist threats, coordinates preventive plans, and organizes incident re-sponses.150 “The FBI runs the Terrorism Threat Investigation Center. . . . The U.S. Department of Agriculture (USDA) has a number ofprograms that concentrate on identifying foreign animal diseases. Na-tionally recognized experts can also help local law enforcement agen-cies create a prevention and response plan.”151 “The NIJ is committedto helping sheriffs and other local law enforcement first responders de-velop a prevention plan and a response plan to mitigate the impact ofagroterrorism.”152

In addition, the NIJ conducts the Terrorism Research Sympo-sium.153 In public-private partnership, the DHS, USDA, FBI, and Foodand Drug Administration (FDA), “will collaborate with private industryand the States in a joint initiative, the Strategic Partnership ProgramAgroterrorism (SPPA) Initiative.”154

Private educational institutions also bring much talent and capa-bility to the efforts to counter and combat agroterrorism and ecoterror-ism. “Several colleges around the country offer training to improve lawenforcement’s ability to respond to agroterrorism. . . . help local agen-

148 Id.149 Id.150 See id.151 Id.152 Id.153 Id.154 U.S. DEPARTMENT OF AGRICULTURE, HOMELAND SECURITY: STRATEGIC

PARTNERSHIP PROGRAM AGROTERRORISM (SPPA), http://www.usda.gov/wps/portal/?contentidonly=true&contentid=content_sppa.html (last visited Mar.1, 2009).



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cies with training[,]” and promote college train the trainer programs oncombating agroterrorism.155 Academia is also establishing, through pub-lic-private partnerships, various Homeland Security Centers of Excel-lence (HS-Centers) to “[empower] the best scientific minds at [U.S.]universities to tackle the challenges of agro-terrorism . . . [to] ensure thebio-security and safety of the [U.S.] food supply.”156

Schmitt emphasizes that identifying and stopping terrorismthreats before they happen is crucial to law enforcement, but this sort oflaw enforcement requires public-private partnerships: “[p]artnerships—the best way to prevent an occurrence of agroterrorism and the onlyway to contain one—must be created among the local sheriff and farm-ers, ranchers, meatpackers, truckers, feedlot owners, and other criticalmembers of the food-supply chain in the jurisdiction.”157

Law enforcement’s role post-agroterrorism or ecoterrorism de-pends upon the extent of the incident, and the availability of local, state,and federal authorities. Schmitt sets forth three priorities, based uponNIJ research and best practices:

• First, “establish and enforce a strict quarantine aroundthe affected area.”158

• Second, construct “State-wide roadblocks to help con-tain the disease.”159

• Third, conduct “primary crimescene investigation, in-cluding collection of tissue from infected animals andan attempt to identify suspects . . . [and] the affectedareas would have to be destroyed and disposed of.”160

Agroterrorism expert Cain said:

155 SCHMITT, supra note 145.156 U.S. Research to Combat Agro-Terrorism, CHANDIGARH AGRIC. TRIB., Dec. 15,2003, available at http://www.tribuneindia.com/2003/20031215/agro.htm#3.157 SCHMITT, supra note 145.158 Id.159 Id.160 Id.



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The experts appear to agree on one thing. The cost interms of damages is directly proportional to the time ittakes to diagnose the disease. The longer it takes to di-agnose a disease, the more it could spread and cause po-tentially extensive losses of production and exports dueto sanctions against the U.S.161

Cooperation among law enforcement agencies at all levels repre-sents an important component of a comprehensive response to terrorismand enables criminals and terrorists to be brought to justice162 (the pros-ecution and defense of such cases is well beyond the scope of this arti-cle). In the U.S., according to Jarboe, this cooperation assumes its mosttangible operational form in the forty-four city-based and oriented JointTerrorism Task Forces (JTTFs) established in across the nation:

These task forces are particularly well-suited toresponding to terrorism because they combine the na-tional and international investigative resources of theFBI with the street-level expertise of local law enforce-ment agencies. Given the success of the JTTF concept,the FBI has established 15 new JTTFs since the end of1999. By the end of 2003 the FBI plans to have estab-lished JTTFs in each of its 56 field offices. By integrat-ing the investigative abilities of the FBI and local lawenforcement agencies, these task forces represent an ef-fective response to the threats posed to U.S. communitiesby domestic and international terrorists.163

V. CONCLUSION

India and the U.S. share much in terms of common goals of theirpeoples, their democratic principles, and common threats to their secur-ity. Towards the ends of a common counterterrorism strategy, the twonations: concluded a Mutual Assistance Treaty on law enforcement andcounterterrorism; held two meetings of the Joint Working Group on

161 CAIN, supra note 28, at 2.162 See SCHMITT, supra note 145 (“Preventing an agroterrorism attack will require aconcerted, coordinated effort by all levels of law enforcement.”).163 Jarboe, supra note 4, at 4.



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Counterterrorism; formed the Defense Policy Group; launched initia-tives to combat cyber-terrorism; supported information security; andpromoted military-to-military cooperation.164

“High level visits between Indian and U.S. leaders from 2002through 2004 have also helped advance, in former Indian Prime Minis-ter Vajpayee’s words, ‘the next steps in the U.S. and India strategicpartnership.’”165

This article is an elemental, cursory survey of potential agroter-rorism and ecoterrorism threats posed to the U.S. and India, some pre-ventive and remedial solutions to those scourges, and suggestions ofpossible ways ahead in this critical effort.

In closing this article, allow me to offer two quotes sharing themutual goals and aspirations of the world’s two great democracies:

In the long run, the United States and India understandthat winning the war on terror requires changing the con-ditions that give rise to terror. History shows us the way.From the East to West, we’ve seen that only one force ispowerful enough to replace hatred with hope, and that isthe force of human freedom.166

As two democracies, we are natural partners in many re-spects. . . . I believe we are at a juncture where we canembark on a partnership that can draw both on principleas well as pragmatism. We must build on this opportu-nity. . . . India is today embarked on a journey inspiredby many dreams. We welcome having America by ourside. There is much we can accomplish together.167

164 Govern, Kevin H. Security Assistance Cooperative Approaches toCounterterrorism, DISAM J. SECURITY ASSISTANCE MGMT., Summer 2005, at 14,available at http://www.disam.dsca.mil/DISAM1/pubs/Vol%2027_4/Govern.pdf.165 Id. at 15.166 The White House, President Discusses Strong U.S.-India Partnership in NewDelhi, India (March 3, 2006), http://www.whitehouse.gov/news/releases/2006/03/20060303-5.html.167 Singh, supra note 1.



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APPENDIX 1

CONTINENTAL U.S. AGRICULTURE, BY LOCATION

168

168 MONKE, supra note 3, at 5.



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APPENDIX 2

HOMELAND SECURITY FUNDING FOR AGRICULTURE, BY SOURCE

169

169 Id. at 32.



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APPENDIX 3

BILLS IN 109TH CONGRESS ADDRESSING AGROTERRORISM

(For Updates, see http://www.govtrack.us/congress/billsearch.xpd)

Committee Status (As ofBill Jurisdiction November 2006)

S. 572 (Akaka) Homeland Homeland Security and Reported by committee onSecurity Food and Governmental Affairs 12/15/2006Agriculture Act S.Rept. 109-209

S. 573 (Akaka) Agriculture Referred to committeeAgricultural Security Incorporated into S. 975Assistance Act

S. 975 (Lieberman) Health, Education, Committee hearing heldProject BioShield II Act Labor, and Pensions 7/21/2005Title 27 (Countermeasures S.Hrg. 109-210Against Agroterrorism)

S. 1532 (Specter) Agriculture Referred to committeeAgroterrorism PreventionAct

H.R. 4239 (Petri) Judiciary Referred to committeeS. 1926 (Inhofe)Animal Enterprise TerrorismAct170

170 Id. at 53.

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